Streamlined Filing Compliance Procedures Under OVDP
In addition to the formal Offshore Voluntary Disclosure Program, the IRS offers Streamlined Filing Compliance Procedures for certain qualified taxpayers.
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How to Complete the Pre-clearance Phase of the OVDP
Before a taxpayer even makes a submission to the Offshore Voluntary Disclosure Program, he or she must successfully complete a pre-clearance phase.
How to Avoid Criminal Charges Facing Taxpayers Who Do Not Participate in OVDP
In addition to the numerous civil penalties potentially facing taxpayers who fail to participate in the Offshore Voluntary Disclosure Program, there are also some serious criminal charges that may result if the IRS
Case Resolution Under the IRS OVDP
What Options Are Available for Case Resolution Under OVDP?
At the end of the Offshore Voluntary Disclosure Program process, the IRS will attempt to come to a closing agreement with the taxpayer.
History of the Offshore Voluntary Disclosure Program
The IRS Criminal Investigation division has a longstanding practice of considering a taxpayer’s timely, accurate, and complete voluntary disclosure in determining whether or not to pursue criminal prosecution against the taxpayer.
How To Avoid Civil Penalties for Failing to Apply to OVDP
A previous article on this topic addressed the civil penalties potentially applying to taxpayers who qualify for the Offshore Voluntary Disclosure Program but fail to apply.
What to Expect at a Tax Court Trial
If you are preparing for a Tax Court trial, you likely have many questions regarding what to expect.
Tax Litigation Following the Notice of Deficiency
Receiving a statutory notice of deficiency is a turning point for the taxpayer’s tax litigation case.
2 Steps to Successfully Enrolling in the IRS OVDP
In order to qualify for the Offshore Voluntary Disclosure Program, a taxpayer must comply with all the requirements set forth by the IRS.
Choice of Judicial Forum in Tax Litigation
When a taxpayer decides to pursue tax litigation against the IRS, he or she generally has three choices for judicial forum: Tax Court, the Claims Court, and Federal District Court.